Supreme Court of Iowa
Renee Hummel v. Adam B. Smith, Adam Smith, M.D., P.C., and Tri-State Specialists, L.L.P.
December 22, 2023
Summary
The court held that Iowa's medical-malpractice expert-qualification statute requires a certificate-of-merit expert to possess a current, active license authorizing practice in the same or a substantially similar field as the defendant. Because the plaintiff's expert held inactive or retired licenses when he signed the affidavit and report, the affidavit did not substantially comply with the statutory requirements. The court reversed the order denying the defendants' motions and remanded for entry of judgment in their favor.